This editorial letter originally appeared in WWD March 2021 issue as "The LCRR is Coming"
The cover story for this month is about the newly approved and published Lead & Copper Rule Revision or LCRR. It’s a critical piece of regulation that will have wide-ranging impacts across the drinking water industry, but there’s one big catch with that right now: a regulatory freeze from the presidential administration.
On President Joe Biden’s first day in office, the White House Chief of Staff Ron Klain issued a memo calling for a regulatory freeze that directly impacts the LCRR (read more in on page 8). It could result in a small delay in the effective date and may also result in additional changes to the language if another 30-day comment period is initiated.
WWD has presented the information as it was published in the Federal Register in this month’s cover story, despite the possibility that changes could be made. We did this because we — and many other industry professionals I’ve corresponded with — believe you should be preparing for the new rule regardless.
Sure, the numbers and the details may change, but the core values and structure is likely to remain the same. Utilities will be required to increase the rate of sampling and to conduct it differently. They will also have to generate educational material about the hazardous effects of lead and water and prepare to share it with the public upon their request.
Perhaps most importantly, utilities will need to inventory the pipes in their system and create a plan that will replace all lead service lines over time. For many utilities this will be a major hurdle. I know from personal experience that small water districts may not have GIS or mapping of their system. Instead, the information is locked in the brain of a long-time employee or director of public works. The going recommendation: grab some cups of coffee and a notebook and ask lots of questions to get that legacy knowledge down on paper.
One aspect of the rule that did not make it into our coverage in this print issue is the corrosion control agents aspect. I highly recommend all utilities reading this to review the LCRR in full to ensure a complete understanding of what you will be compelled to do when the effective date hits.
Whether in its January 15 published form or an updated version, the LCRR is coming, so plan accordingly.